Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Reopening of assessment was held time-barred where a section 148 notice was issued after the pre-amendment six-year limitation, because the first proviso to section 149(1) operates as a substantive restriction preventing issuance of notices for assessment years to which the old regime's period had expired; therefore the reassessment under section 147 read with remedial provisions could not stand. The fifth and sixth provisos, which exclude certain periods for computing limitation under the amended provision, do not extend or revive notices prohibited by the first proviso, so the reassessment was quashed for want of jurisdiction.
Reopening of assessment was held time-barred where a section 148 notice was issued after the pre-amendment six-year limitation, because the first proviso to section 149(1) operates as a substantive restriction preventing issuance of notices for assessment years to which the old regime's period had expired; therefore the reassessment under section 147 read with remedial provisions could not stand. The fifth and sixth provisos, which exclude certain periods for computing limitation under the amended provision, do not extend or revive notices prohibited by the first proviso, so the reassessment was quashed for want of jurisdiction.
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